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HomeMy WebLinkAbout06-0942 t:-- , , r t l . COMMQNWEALTH OF PENNSYLVANIA OOUNTY OF: CUMBEllLABD !Z, 9'1"). /~,.' "NOTICE OF JUDGMENTfTRANSCRIPT uti-4 CIVIL CASE PLAINTIFF: NAME and ADDRESS 'sENT CUD: LIMITED PAllTll1BllSBIP -, 5351 JAYCEE AVkmu~ BARRISBURG, PA 17112 L -.J VS. Mag_ Dist No 09~3-04 MDJ Name: Hon TBOMAS A. PLACET Add"" 104 S SPOllTXIIlG BILL 1lD MECBAIIl'ICSBURG, PA , ," (7i'1)7~i':823, 0 , 17050 '"" , DEFENDANT: NAME afldADDRfOSS IaOBERTS, WEBB, ET AL. 104 DOG WOOD BILL DRIVE GOOSE CRBBK. SC 29445 L -, BEIIl'T CUEX LIMITED PAllTll1BRSBIP 5351 JAYCEE AVEau~ BARRISBURG, PA 17112 -.J . Docket No.: CV-0000560-05 Date Filed: 10/12/05 THIS IS TO NOTIFY YOU THAT: "J8d!'jftlent " 't:',: ,,,;,, [i] Judgment was entered for: ,nR!!'A1JLT: Jm)aMRIII'I' PLT!!' (Name) 1""1111'I' 1"1lRtn: T,TlIT'1'lln P:t.ll'l'1ll1l1lRlfTP [i] Judgment was entered against: (Name) lI:t.lfnw, WR1i11l11T.T. in the amount of $ (Date of Judgment) 1/12/0fO 2,A42 00 on: D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. (Date & Time) Amount of Judgment $ 2.745.00 Judgment Costs $ 97.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.842.00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ ANY PARTY HAS THE RIGHT TO APPEAL ~ITHIN 30 Oi\YS AFTER THE ENTRY OF,JUOGMENT BY,FlpNG A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURTOF COMMON PLEAS, CIVIL OIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REOUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA YS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ,~ .~ ]1 i ~: ! t ~ 1 ~Date Magisterial District Judge I certify that this is a true a d correct copy of the record of the p oceedings containing the judgment ~ Date t4 "- -- , Magisterial District Judge My commission expires first Monday of January, 2010 . SEAL Aope 315-05 DATE PRIIIl'TED: 1/12/06 10.42.25 AM o c ._" ,. ~, ,',~ C~:> C;f', (J -n ,-1 :J.;'i I r'r'- ';-l,;:q ~,1 -,-' ').J. '-j';,': "n i:j~~ ""'-1 ;:~ ,;::I ,< .." 1"'"1 0::; -.J -::' N l'.) COMM()NWEALTH OF PENNSYLVANIA eOUNTYOF: CUKBBRLARD ;"(i-, ,NOTICE OF JUDGMENTfTRANSCRIPT .I CIVIL CASE PLAINTIFF: NAME and ADDRESS 'sENT CRBEK LIMITED PARTNERSHIP I 5351 JAYCEE AVJ5IlIUI5 HARRISBURG, PA 17112 Mag_ Dist. No' 09-3-04 MD,) Name HOIl THOMAS A. PLACEY Add"" 104 S SPORTING RILL lID MBCIlAIl'ICSBURG, PA L -.l VS. T''''hOM(717) 761'-'8230 17050 DEFENDANT; NAME and ADDRESS 'ROBBRTS, WEBB, ET AL. 104 DOG WOOD HILL DRIVE GOOSB CRBB~, BC 29445 L I BENT CREEK LIMITED PARTNERSHIP 5351 JAYCEB AVEnul5 HARRISBURG, PA 17112 Docket No.: CV-0000560-05 Date Filed: 10/12/05 -.l . THIS IS TO NOTIFY YOU TH,Il. T: Judgment! '. ", .,,!;,. '..'>W" 'IJKP.ABLT .nwaM1nM' PLTl!' . [i] [i] Judgment was entered for: (Name) 'R1OI'I' C"'!'D1lll"lr T.TVTT'Rn 'P'llV'1'1I'R'DA'RT'D Judgment was entered against: (Name) ....:&11011. lr'R1llTla.T.T. in the amount of $ 2 A42 no on: (Date of Judgment) 1112/0'; o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) O Amount of Judgment Subject to Attachmenti42 Pa.C.S. ~ 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 2.745.00 Judgment Costs $ 97.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,842.00 ~6st Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS TH~ RIGljTTO ,APPEAL W,ITHIN 30 Oil YS AFJ;ER1;HE ENTRY PF.JUDGMENT BYFI~IN9A NOTIC!, OF APPEAL WitH tHE PRdTHONOTARY!cLERk Oi"THECOURTOF COMMON PLIOAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~Date I certify that this is a true a \ \ 'J-l OIP Date I . Magistl)rial District Judge d correct copy of the record of the p oceedings containing the judgment. - --.." - , Magisterial District Judge My commission expires first Monday'of January, 2010 SEAL AOPC 315-05 DATB PRIlIITED: 1/12/06 10:42:50 AM , 0 ....., C) c.=:; C c:;,-.;. "'" u~ ~ .-1 " ... ;!~-CI CO ' "t:: -n I 2_ ~ ~lJ '-"' -.l , (~" ,. ."1'. -n . .:~! "T", :::;:: (") ~5 n-I Tv ., N ?B -< .. . OOM~'ONWEAL TH OF PENNSYLVANIA OOUNTY OF: CUllBERLAlIID 09-3-04 NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'sERT CREEK LIMITED PARTNERSHIP I 5351 JAYCEE AV~u~ HARRISBURG. PA 17112 L .J VS. Mag. Dist No MDJ Name: Hon THOMAS A. PLACET Add"" 104 S SPORTING HILL RD MECHARICSBURG, PA T"'pho" (717) 761-8230 17050 DEFENDANT: NAME and ADDRESS 'ROBERTS, WEBB. ET AL. 104 DOG WOOD HILL DRIVE GOOSE CREEK. SC 29445 L I BERT CREEK LIMITED PARTNERSHIP 5351 JAYCEE AV~u~ HARRISBURG, PA 17112 Docket No.: CV-0000560-05 Date Filed: 10/12/05 .J - THIS IS TO NOTIFY YOU THAT: Judgment: DEPAULT JUDc.Dnn1'I' PLTP [iJ [iJ Judgment was entered for: (Name) R...... ('I'R'R1l'R" T.TMT'I'Rn Pa.'R-rN'II!'Df:lR'T'D Judgment was entered against: (Name) RATT_. T"RAVT8 in the amount of $ 2,A42 00 on: (Date of Judgment) 1/12/0/; . . o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) O Amount of Judgment Subject to Attachment/42 Pa.O.S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 2.745.00 Jud.Qment Oosts $ 97.00 ~ $ .00 l;iest on Judgment A prney Fees $ .00 Tlrtal $ 2.842.00 ('j , ./ $ z:: Judgment Oredits ost Judgment Oosts $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL. SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I \ \2-\ 0'"' Date Magisterial District Judge I certify hat this is a true a \ \ 1. \)I, Date d correct copy of the record of the p oceedings containing the judgment. ,~\ 14 ~~ , Magisterial District Judge "- My commission expires first MondliY of January, 2010 SEAL AOPC 315-05 DATE PRINTED: 1/12/06 10:43:09 AM ~ f l. t..l l~ "tt..""'- \..J - ~ --..: ~ . -t::. )J V". )J , --. 'V', ., \ (... "- ....... \ :-1 4::. ~ ~ ~ ~.~ ~ "t' ~ ~ . ~~ ~\~ tJ ~ 0 Co: ~::~ -n -""1"1 :::1 : '~~~ -p. ;:; ~,/! 1"0 '~-?, N ?o ..<< - ~ ,~~ ~--:::- f' ~ l\ i- ~ ~ ~ itl Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO, 06-942 Wendell Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant CIVIL ACTION - LA W PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, Bent Creek Limited Partnership, and hereby petitions the Honorable Court to issue a Rule to Show Cause as to why relief in the instant Petition should not be granted upon the Defendant, Wendell Mahon and the Defendant's employer, Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716, in support thereof avers as follows: 1. This matter arises out of a dispute concerning a residential lease. 2. Judgment was entered against the Defendant by District Justice Thomas A. Placey, Magisterial District 09-3-04 on January 12,2006 in the amount of $2,745.00, Docket Number CV-0000560-05. Post judgment costs increased this amount to $2,842.00, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on February 17,2006, under Docket Nwnber 06-942 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfy Judgment Docket Number CV-0000560-05. No response was received from defendant. 5. The Defendant is currently employed at Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716. 6. Pursuant to 42 Pa. C.S.A. Section 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, this judgment debtor-tenant. 7. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfY the judgment, as permitted by 42 Pa. C.S.A. Section 8127. , 8. Copies of the District Justice Judgment and the proposed attachment order are attached hereto. 9. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed rule to show cause against both the Defendant, Wendall Mahon and his current employer, Southeastern Mechanical Service, 1615 IISth Avenue North, St. Petersburg, FL 33716. Respectful! y S ubmi tted: l' ).!JDy 1liA<2;y,p~ 5351 Jaycee Avenue Harrisburg, PA 17112 (717)657-5729 Date: CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiffs Petition For A Rule To Show Cause: Why An Order Granting Wage Attachment Should Not Issue upon the person and in the manner indicated below, which service satisfies the requirement ofPa, R.C.P. 440: Service by certified mail, addressed as follows: Wendell Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Respectfully Submitted, Date: d. )3 DC.'} J Pietro Leone, Attorney PABar#85127 5351 Jaycee Avenue Harrisburg,PA 17112 717-657-5729 . Jjuo:gllicnt QIcrtifiratc Common Pleas of Cumberland County, Carlisle, Pennsylvania I:Jgd Ctu;e. ~m::k( I \~It/.J . p~ . /3;;t.l;U'J~ No. fJ?". ";'1/;;1.. C/~J Judgment entered for 1/< $d5"<;/,,),c:::7(! Dated /- /d 1)6 Time M. Payable ~uicd!I Af ~! tv.un..ct"11 A1akn \~{k~1 A<r.2Zi1 Tax and entry paid by I'~ $ /7"01 c;- ~~ r ,54~ Wu. ~. Prothonotary ,.,:,- NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTJFF: NAME and ADDRESS ~ENT CREEK LIMITED PARTNERSHIP I 5351 JAYCEE AVENUE HARRISBURG, PA 17112 . COMMCNWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLll."'D Mag Disl No 09-3-04 MDJ Name: Hon THOMAS A. PLACEY Add"" 104 S SPORTING HILL RD MECHANICSBURG, PA L VS, NAME and ADDRESS -.J 'T";;;O;" (T17) 761'-8230 DEFENDANT: r;: .. ..' ',' ROBERTS, WEBB, ET AL. 104 DOG WOOD HILL DRIVE GOOSE CREEK," SC 29445 L , 17050 BENT CREEK LIMITED PARTNERSHIP 5351 JAYCEE AVENUE HARRISBURG, PA 17112 Docket No,: CV-0000S60-05 Date Filed: 10/12/05 THIS IS TO NOTIFY YOU THAT: ':"::~"":'jilld['fi'treht::::;"'<i ~::i:,"'!~",::1~~;;;c '. ':~"DEFAULT.: 'JUDGMEtilTPLTF. [i] [i] Judgment was entered for: (Name) RllWT ~'R'R''RT T.T'M'T"1"':ln 'Pa'R~llR'R'T'P Judgment was entered against: (Name) Mll'ROli, WRlinli:T,T, in the amount of $ (Date of Judgment) 1/12/0/; 2,A42 00 on: o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) .J ..~- ~ tc."' "NY PARTY HAS ~HE RIGHT TQ,APpEAL ~ITHIN?O Di\Ys ~Fr:ER T,HEENTRYQF,JUDGMEf>JT BY.FllING A r;OTICE OF APPEAL WITH THE PROTHONOTARYiCLERK OFTHE COURT OF COMMON PLEAS, civiL DIVISION. Yciu MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~ /].~ tA/'---- /, ~ Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total O Amount of Judgment Subject to Attachment/42 Pa.C.S. (} 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 1 \ IZ.\ \)1:- Maglsterial District Judge Date $ 2.745.00 $ 97.00 $ .00 $.00 $ 2,842.00 ------------ ------------ I C6i1ify that this is a true 0.1 d correct copy of the record of the p oceedings containing the judgment. ~ Date (A, c. -.." , Magisteri8.1 District Judge M~' commission expires first Monday of January, 2010 SEAL AOPC 315.05 1/12/06 10:42:25 AM DATE PRINTED: C"'> 1...;) ------ . . , Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYL VANIA Vs NO. 06-942 Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant CIVIL ACTION - LAW PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, Bent Creek Limited Partnership, and hereby petitions the Honorable Court to issue a Rule to Show Cause as to why relief in the instant Petition should not be granted upon the Defendant, Travis Batten and the Defendant's employer, Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716, in support thereof avers as follows: 1. This matter arises out of a dispute concerning a residential lease. 2. Judgment was entered against the Defendant by District Justice Thomas A. Placey, Magisterial District 09-3-04 on January 12,2006 in the amount of$2,745.00, Docket Nwnber CV-0000560-05. Post judgment costs increased this amount to $2,842.00, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on February 17,2006, under Docket Nwnber 06-942 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfY Judgment Docket Number CV-0000560-05. No response was received from defendant. 5. The Defendant is currently employed at Southeastern Mechanical Service, 1615 118lh Avenue North, St. Petersburg, FL 33716. 6. Pursuant to 42 Pa. e.S.A. Section 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, this judgment debtor-tenant. 7. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfy the judgment, as permitted by 42 Pa. C.S.A. Section 8127. . '. 8. Copies of the District Justice Judgment and the proposed attachment order are attached hereto. 9. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed rule to show cause against both the Defendant, Travis Batten and his current employer, Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716. Respectfully Submitted: Date: J-}3-fj(P ~ ietro Leone Attorney, P A Bar #85127 5351 Jaycee Avenue Harrisburg, P A 17112 (717)657-5729 d. - , CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiffs Petition For A Rule To Show Cause: Why An Order Granting Wage Attachment Should Not Issue upon the person and in the manner indicated below, which service satisfies the requirement ofPa. R.C.P. 440: Service by certified mail, addressed as follows: Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Respectfully Submitted, Date: d - d3 {){c I2t ;J ~. By: Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17II2 717-657-5729 . " Wub-gmettt QIcrtifiJ:ute Common Pleas of Cumberland County, Carlisle, Pennsylvania ~It.:t ~,.e X~( I \\.hz1t./J p/~. ,;; ~ /. . . .' -.., ;?' /I /a;vCJ-/<u..1-.~ No. (J?" - tlf 0<-- l-fL,/-J' Judgment entered for tJ,,: $db<;O,a;:J Dated /- /,;; 06 Time M. Payable ~nk# /H~l IV$-r~/! /J14~/1 \V..a.(k~'1 A<f'~L Tax and entry paid by ,:~ $ /7'c/ S ~n4: rj4? ~. ~.' Prothonotary 1'-,,,,- COr.A~'ONVVEAL TH OF PENNSYLVANIA COUNTY OF' CUMBERLAND ~ 09-3-04 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'BENT CREEK LIMITED PARTNERSHIP I 5351 JAYCEE AVE~u~ HARRISBURG, PA 17112 Mag DisL No. MDJ Name: Hon THOMAS A. PLACEY Add"" 104 S SPORTING HILL 1m MECHAHICSBURG, PA L -.J VS T""ho" (717) 761-8230 17050 DEFENDANT: NAME and ADDRESS 'ROBERTS, WEBB, ET AL. 104 DOG WOOD HILL DRIVE GOOSE CREEK, SC 29445 I BENT CREEK LIMITED PARTNERSHIP 5351 JAYCEE AVENUE HARRISBURG, PA 17112 L Docket No.: CV-0000560-05 Date Filed: 10/12/05 -.J ~- ~ THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF [!] [!] Judgment was entered for: (Name) 'R'R"N"'J' ("II'RR'R1l" T.T'M'TT1nl 'PaVT'N"'Ili1!::::!R'T'P Judgment was entered against: (Name) RlI.TTRW TRlI.VTS in the amount of $ 2 A42 nn on: (Date of Judgment) 1/12/0;; o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 2.745.00 $ 97.00 $ .00 $ .00 $ 2.842.00 O Amount of Judgment Subject to Attachment/42 Pa.C.S. 98127 $ o Portion of Judgment for physical damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA YS IN FULL, SETTLES, OR OTHERW[SE COMPLIES WITH THE JUDGMENT. 1\'\:2,\ 01", --P ~ Magisterial District Judge Date I ceiiify that this [s a true al1d correct copy of the record of the p oceedings containing the judgment. , \ /',1 ~. \ \ \2. \ \){" Date / \ ' Magisterial District Judge My commission expires first Monday of January, 2010 . SEAL AOPC 315-05 DATE PRINTED: 1/12/06 10:43:09 AM -. .') ~ , ) n_t t, v..:: , Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO. 06-942 Kendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant CIVIL ACTION - LA W PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, Bent Creek Limited Partnership, and hereby petitions the Honorable Court to issue a Rule to Show Cause as to why relief in the instant Petition should not be granted upon the Defendant, Kendall Mahan and the Defendant's employer, Southeastern Mechanical Service, 1615 IISth Avenue North, St. Petersburg, FL 33716, in support thereof avers as follows: I. This matter arises out of a dispute concerning a residential lease. 2. Judgment was entered against the Defendant by District Justice Thomas A. Placey, Magisterial District 09-3-04 on January 12,2006 in the amount of$2,745.00, Docket Number CV-0000560-05. Post judgment costs increased this amount to $2,842.00, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on February 17,2006, under Docket Number 06-942 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfy Judgment Docket Number CV -0000560-05. No response was received from defendant. 5. The Defendant is currently employed at Southeastern Mechanical Service, 1615 II 8th Avenue North, St. Petersburg, FL 33716. 6. Pursuant to 42 Pa. C.S.A. Section 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, this judgment debtor-tenant. 7. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfy the judgment, as permitted by 42 Pa. C.S.A. Section 8127. . 8. Copies of the District Justice Judgment and the proposed attachment order are attached hereto. 9. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed rule to show cause against both the Defendant, Kendall Mahon and his current employer, Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716. Respectfully Submitted: Date: ;J/}3 -0 b 41 }.J--- A>ietro Leone Attorney, P A Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717)657-5729 . ~ CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiff's Petition For A Rule To Show Cause: Why An Order Granting Wage Attachment Should Not Issue upon the person and in the manner indicated below, which service satisfies the requirement of Pa. R.C.P. 440: Service by certified mail, addressed as follows: Kendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Date: )- -,;13 -00 Respectfully Submitted, ~;)y y: Pietro Leone, Attorney PABar#85127 5351 Jaycee Avenue Harrisburg, PA 17112 717-657-5729 ~ . . - WUOBm~ut QIcrtifil:atc Common Pleas of Cumberland County, Carlisle, Pennsylvania ~ ~1t1 Cw,e l)s;imJ~ I \\.k~1 P~" /J;;,j;/"J+ No. /,/(;,. 7'</d.. co.,J Judgment entered for !J< $d S'<<o?tl:? Dated / /;; l)6 Time M. Payable ~yui4.# /rf ~l lv~n...d?11 A1ak/1 \it.a,,.(.f~1 A~~L Tax and entry paid by ~ $ /7 -OJ ::: , ~~z.q: /:'. J4? ~ - Prothonotary 1-1-; . COM~-"0NWEALTH OF PENNSYLVANIA COUNTY OF CW.BERLAND .!Yo- t;'i"J.- - , /1' ff NOTICE OF JUDGMENTITRANSCRIPT ,-U.'" CIVIL CASE PLAINTIFF: NAME aM ADDRESS 'BENT CREEK LIMITED PAR~~RSHIP I 5351 JAYCEE AVENUE HARRISBURG, PA 17112 L ~ VS. Mag. Dis1. No. 09-3-04 MOJ Name; Hon THOMAS A. PLACEY Add,." 104 S SPORTING HILL RD MECBANICSBURG, PA T~'.PhoC.': (717) 761'-8230 DEFENDANT; NAME and ADDRESS 'ROBERTS" WEBB, ET AL. 104 DOG WOOD HILL, DRIVE GOOSE CREEK, SC 29445 L I '17050 BENT CREEK LIMITED PARTNERSHIP 5351 JAYCEE AVENUE HARRISBURG, PA 17112 ...J "-'~ ',' <:: .., o r. it '. " ' c:) ~~r..:..; Docket No,: Date Filed: CV-0000560-0S 10/12/05 0 S-- ~; --- 'I;':", "'......-; THIS IS TO NOTIFY YOU THAT: "~--" 'J""dgm en'!"" ", \-. " - -- - I.Jl . , -:." - ~'''~.' -'; _, ",'~'" -' 'DEFAm.T,' JUDGMRNT PLTP "---I"' :0 _...' :-};;:;O':~ .>~\:.-, , [iJ [iJ Mluro",", IrlOTnlH,r, ..-( \::? \",J - :i. Judgment was entered for: (Name) 'R.llllM' r'R'R'R'R' T.TVT-r'Rn 'Pa.'RTWRV5=I'R'T.'P Judgment was entered against: (Name) in the amount of $ (Date of Judgment) 2 1142 00 on: 1/12/0(;, o Defendants are jointly and severally liable, n Damages will be assessed on: o This case dismissed without prejudice, (Date & Time) Amount of Judgment $ 2.745.00 Judgment Costs $ 97.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,842.00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ O Amount of Judgment Subject to Attachment/42 Pa,C's, (I 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ AN'( PARTY HAS TH~ R'GHTTO,APPEAL\X'THIN 30 DAYS AFi;ER1;HE ENTRX pF,JUD<iMEW BYFI~IN9,A t-'OTIC!" OF APPEAL WITH THE PROTHONOTARY!cLERk OF'THECOURT OF COMMON P'LEA'S, 'CIVIL DIVISION: YOU' .. MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL, EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MA Y BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE, UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAG~STER:AL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA YS IN FULL, SETTLES, OR OTHERWISE cor~PUES WITH THE JUDGMENT. Ih~o(. , Magisterial District Judge Date I certify that this is a true a \ \ \2--\ Ole Date I . d c~rrect copy of the record of the p oceedings containing the judgment. I f -- I - , Magisteria.l District ,Judge My commission expires first Monday of January, 2010 SEAL AOPC 315'05 1/12/06 DATE PRINTED: 10:42:50 AM r-....J G " ..... Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant 06-942 CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 6th day of March, 2006, upon consideration of the foregoing petition, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before March 28, 2006; 3. The petition shall be decided under Pa.R.C.P. No. 206.7; 4. Notice of the entry of this order shall be provided to all parties and to the current employer of the Defendant, Southeastern Mechanical Services, 1615118'h Avenue North, SI. Petersburg, FL 33716; 5. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing shall be held on 17'h day of April, 2006, at 2:00 p.m. in Courtroom NO.5 of the Cumberland County Courthouse. If no answer to the Rule to Show cause is filed by the required date, the relief requested by the Plaintiff shall be granted. By the Court, ~~~ M. L. Ebert, Jr., r[: : 1 " \ 1!':'\1: , - .... Pietro Leone, Esquire Attorney for Plaintiff Kendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Southeastern Mechanical Se 1615 118'h Avenue North Sl. Petersburg, FL 33716 bas j- l - f.J {p (l1Jf,u.~a ices ~ )15 ~......~... Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant 06-942 CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 6th day of March, 2006, upon consideration of the foregoing petition, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before March 28, 2006; 3. The petition shall be decided under Pa.R.C.P. No. 206.7; 4. Notice of the entry of this order shall be provided to all parties and to the current employer of the Defendant, Southeastern Mechanical Services, 1615 118th Avenue North, SI. Petersburg, FL 33716; 5. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing shall be held on 17'h day of April, 2006, at 2:00 p.m. in Courtroom NO.5 of the Cumberland County Courthouse. If no answer to the Rule to Show cause is filed by the required date, the relief requested by the Plaintiff shall be granted. By the Court, M~~J~~ (....: :i r -. ....._ '" Pietro Leone, Esquire Attorney for Plaintiff Travis Batten 1 04 Dog Wood Hill Drive Goose Creek, SC 29445 Southeastern Mechanical Se 1615 118th Avenue North SI. Petersburg, FL 33716 bas )- 7-u(, ~ ~'d~ J~ "'" '. Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant 06-942 CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 6th day of March, 2006, upon consideration of the foregoing petition, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before March 28, 2006; 3. The petition shall be decided under Pa.R.C.P. No. 206.7; 4. Notice of the entry of this order shall be provided to all parties and to the current employer of the Defendant, Southeastern Mechanical Services, 1615 118th Avenue North, St. Petersburg, FL 33716; 5. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing shall be held on 17'h day of April, 2006, at 2:00 p.m. in Courtroom NO.5 of the Cumberland County Courthouse. If no answer to the Rule to Show cause is filed by the required date. the relief requested by the Plaintiff shall be granted. By the Court, M~b~J'~ r~ . l ~ I ! . . ~ Pietro Leone, Esquire Attorney for Plaintiff Wendall Mahon 104 Dog Wood Hill Drive Goose Creek, SC 29445 Southeastern Mechanical Se 1615 118'h Avenue North SI. Petersburg, FL 33716 bas 3/ l-() (p ces (]~ ~~ ,J14> Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO. 06-942 Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant CIVIL ACTION - LAW PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206,7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: 1. On February 23, 2006, Plaintiff, Bent Creek Limited Partnership, filed a Petition for A Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue, 2. On March 6, 2006, this Honorable Court issued a Rule to Show Cause with an answer on or before March 28, 2006. 3. The Defendant has not answered the Rule. 4. Pursuant to Pa. R.C,P, 206,7, when a Rule is not answered, the averments of fact may be deemed admitted and the court shall enter an appropriate order. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant its Petition For a Rule to Show Cause Why An Order Granting Wage Attachment Should Not Issue and GRANT a wage attachment against the Defendant's current employer, Southeastern Mechanical Services, 1615 118th Avenue North, St. Petersburg, FL 33716, as well as all current or subsequent employers. Date: 1-- 10. <9(p Respectfully Submitted: ~ fit) Pietro Leo e, ttomey PABar#85127 5351 Jaycee Avenue Harrisburg, P A 17112 (717) 657-5729 CERTIFICATE OF SERVICE 1 hereby certify that I am this day serving Plaintiffs Motion to Make Rule Absolute upon the person and in the manner indicated below, which service satisfies the requirement ofPa. R.C.P. 440: Service by certified mail, addressed as follows: Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Southeastern Mechanical Services 1615 118th Avenue North St. Petersburg, FL 33716 Respectfully Submitted, Date: f- If) . OlP ~ ~,J - By: Pietro Leone, At arney, P A Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 ',1 _-1 ,1', \',,) L.< Bent Creek Limited Partnership 5351 Jaycee Avenue PENNSYLVANIA Harrisburg, PA 17112 Plaintiff APR 2 6 2006 '7 IN THE COURT OF COMMON PLEAS ~ CUMBERLAND, COUNTY, 4 ~.. Vs NO. 06-942 Travis Batten 104 Dog Wood Hill Drive Goose Creek, SC 29445 Defendant CIVIL ACTION - LAW ATTACHMENT ORDER '"' '\ AND NOW, this 1.. 1 day of ~ 9" ,2006, upon consideration of the foregoing Petition for A Rule to Show Why An Order Granting Wage Attachment Should Not Issue, no response being filed by the Defendant, Travis Batten, and the Defendant's employer, Southeastern Mechanical Service, 1615 118th Avenue North, St. Petersburg, FL 33716, it is hereby ORDERED AND DECREED as follows: 1. The Defendant's current employer, Southeastern Mechanical Service, and all subsequent employers of the Defendant are hereby ORDERED to garnish the wages of the Defendant in the amount of 10% of his net wages per pay period until the judgment in this matter is marked satisfied. 2. The amount of the judgment is $2,842.00. 3. The Defendant's current employer, Southeastern Mechanical Service, and all subsequent employers of the Defendant are hereby ORDERED to send checks, for each pay period of the Defendant, in the amount specified in paragraph 1 above, and I made payable to Triple Crown Corporation agent for Bent Creek Limited Partnership to the Office of the Prothonotary at One Courthouse Square, Carlisle, PA 17013, who will then record the amount paid in the docket of this matter and then forward the checks to Triple Crown Corporation, 5351 Jaycee Avenue, Harrisburg, PA 17112. So Ordered, By the Court ~lu.j} -,. ... 8/ :8 L7 'l/t ~'~"Z ,. .""' (,,'!! v ~,U" JUu QUALITY LAWN WORKS, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO. 2006-1092 CIVIL ACTION - LAW STRICKLAND BROTHERS CONSTRUCTION, LLC, Defendant CIVIL TERM PLAINTIFF QUALITY LAWN WORKS, INC. 's ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS Quality Lawn Works, Inc., Plaintiff, by and through its attorney, Jennifer B. Hipp, Esquire, respectfully makes the following Answer to Defendant Strickland Brothers Construction, LLC's Preliminary Objections to Amended Complaint as follows: 1. Denied. The allegations set forth in Paragraph No. 1 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. 2. Denied. It is specifically denied that Quality Lawn Works, Inc. (hereinafter "Quality" or "Plaintiff") "attempts to assert information regarding settlement negotiations between the parties, which settlement negotiations are scandalous, impertinent and/or irrelevant ...". By way of further answer, it is admitted that Quality issued to Strickland Brothers Construction, LLC (hereinafter "Defendant") an invoice in the total amount of twenty thousand ($20,000.00) dollars, a copy of which is attached to Quality's Amended Complaint, marked as Exhibit "A" and incorporated therein. See Amended Complaint, Exhibit "A". 3. Denied. The allegations set forth in Paragraph No. 3 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. 4. Denied. The allegations set forth in Paragraph No.4 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. By way of further answer, it is admitted that Quality issued to Defendant an invoice in the total amount of twenty thousand ($20,000.00) dollars, a copy of which is attached to Quality's Amended Complaint, marked as Exhibit "A" and incorporated therein. See Amended Complaint, Exhibit "A". 5. Admitted. By way of further answer, Quality's Amended Complaint speaks for itself by demanding "judgment against Defendant in the amount of $60,000.00, plus interest, together with the costs of this action, attorneys fees and any and all other relief deemed just and appropriate." 6. Denied. The allegations set forth in Paragraph No. 6 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. 7. Denied. The allegations set forth in Paragraph No.7 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. 8. Denied. The allegations set forth in Paragraph No.8 of Defendant's Preliminary Objections are conclusions of law to which no response is necessary. . WHEREFORE, Plaintiff Quality Lawn Works, Inc. requests that this Honorable Court overrule Defendant's Preliminary Objections and direct that Defendant file its Answer to Quality Lawn Works, Inc.'s Amended Complaint. Respectfully submitted, QUALITY LAWN WORKS, INC. Dated: April 27, 2006 BY: Jennif r B. Hipp, Esquire Bogar & Hipp Law Offices One West Main Street Shiremanstown, Pennsylvania 17011 Telephone: (717) 737-8761 Facsimile: (717) 737-2086 Supreme Court ID No. 86556 . ' QUALITY LAWN WORKS, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO. 2006-1092 CIVIL ACTION - LAW STRICKLAND BROTHERS CONSTRUCTION, LLC, Defendant CIVIL TERM CERTIFICATE OF SERVICE On this date we do swear and affirm that a true and correct copy of Plaintiff Quality Lawn Works, Inc. 's Answer to Defendant's Preliminary Objections to Amended Complaint in the above-captioned matter was served upon Defendant, Strickland Brothers Construction, LLC, by forwarding a copy thereof to Mark W. Allshouse, Esquire, attorney of record for Defendant to the following address, by First Class United States Mail as follows: Mark W. Allshouse, Esquire 4833 Spring Road Shermans Dale, PA 17090 Dated: April 27, 2006 By: Jenn' er Esquire Pa. I.D. No. 86556 1 West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 Facsimile: (717) 737-2086 s:) ~ C--::~ r,:"J 2:;'" r") ,., ::D" ;S r--> -J -r'~ II :;::,:" "F! o c.." ~,~ :-<. ;- .. QUALITY LAWN WORKS, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO. 2006-1092 CIVIL ACTION - LAW STRICKLAND BROTHERS CONSTRUCTION, LLC, Defendant CIVIL TERM PLAINTIFF OUALITY LAWN WORKS, INC.'S PRAECIPE FOR LISTING CASE FOR ARGUMENT 1. State matter to be argued: Defendant Strickland Brothers Construction, LLC's Preliminary Objections to Plaintiff Quality Lawn Works, Inc.'s Complaint and Plaintiff's Answer to Defendant's Preliminary Objections. 2. Identify counsel who will argue case: (a) for Plaintiff: Jennifer B. Hipp, Esquire Bogar & Hipp Law Offices One West Main Street, Shiremanstown, PA 17011 Telephone number: (717) 737-8761 Facsimile number: (717) 737-2086 (b) for Defendant: Mark W. Allshouse, Esquire 4833 Spring Road, Shermans Dale, PA 17090 Telephone number: (717) 582-4006 Facsimile number: (717) 582-7476 3. We will notify all parties in writing within two days that this case has been listed for argument. # 4 . Argument Court date: Dated: April 27, 2006 May 17, 2006 Respectfully submitted, BY: Jennif Esquire Bogar & Hipp Law Offices One West Main Street Shiremanstown, Pennsylvania 17011 Telephone: (717) 737-8761 Facsimile: (717) 737-2086 Supreme Court ID No. 86556 Attorney for Quality Lawn Works, Inc. ~ . QUALITY LAWN WORKS, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO. 2006-1092 CIVIL ACTION - LAW STRICKLAND BROTHERS CONSTRUCTION, LLC, Defendant CIVIL TERM CERTIFICATE OF SERVICE On this date we do swear and affirm that a true and correct copy of Plaintiff Quality Lawn Works, Inc. 's Praecipe for Listing Case for Argument in the above-captioned matter was served upon Defendant, Strickland Brothers Construction, LLC, by forwarding a copy thereof to Mark W. Allshouse, Esquire, attorney of record for Defendant to the following address, by First Class United States Mail as follows: Mark W. Allshouse, Esquire 4833 Spring Road Shermans Dale, PA 17090 Dated: April 27, 2006 By: Jen Esquire Pa. 1.0. No. 86556 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 (j ,...... ,-:.'. .. f'o...;) C::..:> C."-::J ~:,:r' (, -n ::::j rt, :!] rH" iT~ c;: )> "'",") ;;<.J ,',) -l (L 1 \..0 .:.~, ..-j.; ,...1.... :__,m :;E~~ Cl -..J '-q :.<.: